Which battery category do I have?

Whether you need a battery passport depends only on the battery category. The Batteries Regulation (EU) 2023/1542 defines five categories (Art. 3(1), points 9 to 14). From 18 Feb 2027, LMT batteries, electric vehicle batteries and industrial batteries above 2 kWh need a passport (Art. 77(1)). This also applies to batteries built into a product, such as an e-bike.

The five categories

• Electric vehicle battery: powers the traction of cars, trucks, buses and trailers (categories M, N, O), or of category L vehicles (e.g. e-motorcycles) if it weighs more than 25 kg. Battery passport: yes.
• LMT battery (light means of transport): sealed, 25 kg or less, powers wheeled vehicles driven by an electric motor alone or by motor and human power, e.g. e-bike, pedelec, e-scooter, e-moped. Battery passport: yes.
• Industrial battery: specifically designed for industrial use or intended for it after repurposing, plus any other battery above 5 kg that is none of the other categories. Battery passport: only above 2 kWh.
• SLI battery: for starting, lighting or ignition, also as an auxiliary or backup battery in vehicles and machinery. Battery passport: no.
• Portable battery: sealed, 5 kg or less, not specifically designed for industrial use and none of the other categories, e.g. batteries in power tools, laptops, phones or power banks. Battery passport: no.

Check in this order

The definitions are mutually exclusive. The quickest way is to go from top to bottom and stop at the first question that fits:

1. Does the battery power the traction of a road vehicle of category M, N or O, or of a category L vehicle while weighing more than 25 kg? Then it is an electric vehicle battery.
2. Does it power a wheeled vehicle, is sealed and weighs 25 kg or less? Then it is an LMT battery.
3. Is it meant for starting, lighting or ignition? Then it is an SLI battery.
4. Is it sealed, 5 kg or less and not designed for industrial use? Then it is a portable battery.
5. Everything else is an industrial battery. Then energy decides: above 2 kWh it needs a passport.

Typical examples

• E-bike or pedelec battery, e-scooter battery: LMT battery, passport required.
• Traction battery of an electric car, or of an e-motorcycle above 25 kg: electric vehicle battery, passport required.
• Home and commercial storage (usually 5 to 30 kWh): industrial battery above 2 kWh, passport required.
• Forklift traction battery: industrial battery (not a road vehicle, heavier than 25 kg), passport required above 2 kWh.
• Portable power station above 5 kg: industrial battery. At 1 kWh no passport, at 3 kWh passport required.
• 12 V starter battery in a car: SLI battery, no passport.
• Battery of a cordless drill, laptop or power bank: portable battery, no passport.

Calculating the 2 kWh threshold

The threshold only applies to industrial batteries and refers to energy, not weight. If the data sheet only gives the capacity in ampere-hours, multiply nominal voltage by capacity: a storage unit with 51.2 V and 100 Ah has 5.12 kWh and needs a passport. A module with 12.8 V and 100 Ah has 1.28 kWh and does not.

Common misconceptions

• "My battery weighs only 3 kg, so it is a portable battery." Wrong if it powers an e-bike. Traction batteries for e-bikes, e-scooters and other light wheeled vehicles are LMT batteries, however light.
• "The battery is built in, so this does not concern me." Wrong. The Regulation also covers batteries in products, and whoever first places the product on the EU market is responsible for the passport.
• "No battery passport means no obligations." Wrong. From 18 Feb 2027 all batteries need a QR code. Without a passport obligation it leads to the label information, the EU declaration of conformity and the disposal information (Art. 13(6)).

Not sure?

The free obligation check on this site asks for category, capacity and your role and tells you in a few clicks whether you need a passport. For borderline cases such as special vehicles, check the text of the Regulation or get legal advice.